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EPIC E-Verify Comments Final 06.08.11

EPIC E-Verify Comments Final 06.08.11

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U.S. Dept. of Homeland Security Comments of EPICComments on DHS-2011-030 June 8, 20111
 
COMMENTS OF THE ELECTRONIC PRIVACY INFORMATION CENTER Joined ByTHE 5-11 CAMPAIGNTHE ALA WASHINGTON OFFICETHE AMERICAN CIVIL LIBERTIES UNIONTHE AMERICAN POLICY CENTER THE CENTER FOR FINANCIAL PRIVACY AND HUMAN RIGHTSTHE CENTER FOR MEDIA AND DEMOCRACYTHE CYBER PRIVACY PROJECTTHE DEFENDING DISSENT FOUNDATIONTHE ELECTRONIC FRONTIER FOUNDATIONTHE LIBERTY COALITIONPRIVACY ACTIVISMUNITED SIKHSPrivacy ExpertCHIP PITTS, Lecturer of Law at Stanford University Law SchooltoTHE DEPARTMENT OF HOMELAND SECURITY“Notice of Privacy Act System of Records”DHS-2011-0030June 8, 2011By a System of Records Notice ("SORN") published in the Federal Register on May 9,2011, the Department of Homeland Security (“DHS”) and the United States Citizenship andImmigration Services (“USCIS”) proposed to establish a new system of records for the DHS E-Verify RIDE Program.
1
Pursuant to the DHS notice in the Federal Register, the ElectronicPrivacy Information Center (“EPIC") along with a coalition of privacy, consumer rights, and
1
Notice of Privacy Act System of Records, 76 Fed. Reg. 26738 (May 9, 2011),
available at 
http://www.gpo.gov/fdsys/pkg/FR-2011-05-09/html/2011-11291.htm [May 9, 2011 System of Records Notice]
 
 
U.S. Dept. of Homeland Security Comments of EPICComments on DHS-2011-030 June 8, 20112
 
civil rights organizations and individuals hereby submit these comments and recommendationsto address the substantial privacy concerns raised by the proposal.EPIC is a public interest research center in Washington, D.C., established in 1994 tofocus public attention on emerging civil liberties issues and to protect privacy, the FirstAmendment, and constitutional values. EPIC has particular interest in preserving privacysafeguards established by Congress, in the development of new information systems operated bythe federal government.
2
 EPIC routinely analyzes and testifies about databases and verification programs used byfederal entities. In Congressional testimony in 2005, EPIC Executive Director Rotenbergdescribed some of the problems that would likely result from a poorly designed EmploymentEligibility Verification System (“EEVS”), and some changes were made to EEVS based on
2
 
See
,
e.g.
, EPIC: Information Fusion Centers and Privacy, http://epic.org/privacy/fusion/; EPIC: EPIC v. VirginiaDepartment of State Police: Fusion Center Secrecy Bill, http://epic.org/privacy/virginia_fusion/; Statement of LillieConey, EPIC Associate Director, to the Department of Homeland Security Data Privacy and Integrity AdvisoryCommittee (Sept. 19, 2007),
available at 
http://www. epic.org/privacy/fusion/fusion-dhs.pdf; Letter from MarcRotenberg, EPIC Executive Director and John Verdi, EPIC Staff Counsel to Senate Committee on HomelandSecurity and Governmental Affairs and the Senate Subcommittee on State, Local, and Private Sector Preparednessand Integration (Apr. 17, 2008),
available at 
http://www.epic.org/privacy/fusion/EPIC_ltr_Sen_Fusion_Ctrs.pdf;Press Release, EPIC, EPIC Obtains Documents Revealing Federal Role in State Fusion Center Secrecy (Apr. 11,2008),
available at 
http://epic.org/press/041108.html; Freedom of Information Act Request from John Verdi,Director, EPIC Open Government Project to Virginia State Police (Feb. 12, 2008),
available at 
http://www.epic.org/privacy/fusion/VA_FOIA021208.pdf; Complaint, EPIC v. Martin and the Virginia Department of StatePolice (D. Va 2007),
available at 
http://www. epic.org/privacy/fusion/VA_FOIA_lawsuit_032108.pdf; EPIC: OpenGovernment, http://epic.org/open_gov/; EPIC: Spotlight on Surveillance: “National Network” of Fusion CentersRaises Specter of COINTELPRO, http://epic.org/privacy/surveillance/spotlight/0607/; EPIC: Privacy,http://epic.org/privacy/; Statement of Lillie Coney, EPIC Associate Director to ABA Conference, Computing andthe Law: From Steps to Strides into the New Age (June 25-26, 2007),
available at 
http://www.epic.org/epic/staff/coney/surveillance.pdf; Letter from EPIC, et. al to Representative Bennie G. Thompson, Chair,U.S. House of Representatives Committee on Homeland Security and Representative Peter T. King, RankingMember, U.S. House of Representatives Committee on Homeland Security (Oct. 23, 2009),
available at 
http://www.epic.org/security/DHS_CPO_Priv_Coal_Letter.pdf; EPIC: EPIC Alert 15.10, “EPIC Prevails in Virginia FusionCenter FOIA Case,” (May 16, 2008), http://mailinglists.epic.org/pipermail/epic_news/2008-May/000001.html;EPIC: EPIC Alert 14.19, “DHS Privacy Advisory Panel Holds Hearing on Fusion Center,” (Sept. 20, 2007),http://epic.org/alert/EPIC_Alert_14.19.html; EPIC: “DHS Releases Fusion Center Privacy Impact Assessment,”EPIC Alert 15.25 (Dec. 23, 2008), http://mailinglists.epic.org/pipermail/epic_news/2008-December/000017.html;EPIC: “Documents Reveal Federal Role In Fusion Center Secrecy,” EPIC Alert 15.08 (Apr. 17, 2008),http://epic.org/alert/EPIC_Alert_15.08.html; EPIC: Department of Homeland Security Chief Privacy Office andPrivacy, http://epic.org/privacy/dhs-cpo.html.
 
 
U.S. Dept. of Homeland Security Comments of EPICComments on DHS-2011-030 June 8, 20113
 
EPIC’s recommendations.
3
Again in Congressional testimony in June 2007, EPIC urgedCongress to strengthen privacy and security safeguards associated with the EEVS the underlyingdatabases.
4
EPIC has analyzed flaws in such systems in a number of reports.
5
EPIC has alsofocused on employment verification systems as part of its “Spotlight on Surveillance” series.
6
 The 5-11 Campaign is a not-for-profit grassroots campaign set to repeal nationalidentity laws, laws requiring data surveillance specific to identified persons and/or to fitfully stopall appropriations to implement national identity.The ALA Washington Office was established in 1945 to represent libraries on CapitolHill. The ALA was founded on October 6, 1876 during the Centennial Exposition inPhiladelphia, It was created to provide leadership for the development, promotion, andimprovement of library and information services and the profession of librarianship in order toenhance learning and ensure access to information for all. ALA Washington Office's currentstrategic plan, ALA Ahead to 2010, calls for continued work in the areas of Advocacy and Valueof the Profession, Education, Public Policy and Standards, Building the Profession, Membershipand Organizational Excellence.The American Civil Liberties Union ("ACLU")
 
is the nation's oldest and largest civilliberties organization with more than half a million members, countless additional supporters and
3
Marc Rotenberg, Exec. Dir., EPIC,
Testimony and Statement for the Record at a Hearing on H.R. 98, the “Illegal  Immigration Enforcement and Social Security Protection Act of 2005,” Before the Subcomm. on Immigration, Border Sec., and Claims, H. Comm on the Judiciary
, 109th Cong. (May 12, 2005),
available at 
http://www.epic.org/privacy/ssn/51205.pdf.
 
4
Marc Rotenberg, Exec. Dir., EPIC,
Testimony and Statement for the Record at a Hearing on Employment  Eligibility Verification Systems (EEVS) Before the Subcomm. on Social Sec., H. Comm on Ways & Means
, 110thCong. (June 7, 2007), available at http://www.epic.org/privacy/ssn/eevs_test_060707.pdf.
 
5
 
See
EPIC, Social Security Numbers, http://epic.org/privacy/ssn/; EPIC, Secure Flight,http://www.epic.org/privacy/airtravel/secureflight.html; and EPIC, National ID Cards and the REAL ID Act,http://epic.org/privacy/id-cards/.
 
6
 
See
EPIC,
 E-Verify System: DHS Changes Name, But Problems Remain for U.S. Workers
(July, 2007),http://epic.org/privacy/surveillance/spotlight/0707/default.html; EPIC,
National Employment Database Could  Prevent Millions of Citizens From Obtaining Jobs
(May, 2007),http://epic.org/privacy/surveillance/spotlight/0507/default.html.
 

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